📘 Understanding Digital Product Passport Information

A Digital Product Passport is a digital record that accompanies a product throughout its life cycle.

It is designed to:

• Provide reliable information on safety, environmental performance, and composition.
• Support enforcement by market surveillance authorities and notified bodies.
• Facilitate repair, reuse, and recycling by sharing relevant technical data.
• Enable consumers and professional users to make informed decisions.

Because the passport may contain commercially sensitive and security‑relevant information, the regulation specifies who can access which type of data.

This is organized into four principal access levels linked either to the product model or to an individual product.

📜 Access Levels of Information in the Digital Product Passport

🟢 1. Publicly Accessible Information Relating to the Product Model 

This category contains low‑risk information that supports transparency and informed choice for consumers and other public users. It is associated with the product model, not specific units.

Typical publicly accessible Digital Product Passport information includes:

• Product identification and model reference.
• Information on dangerous substances and relevant risk warnings.
• Safe use, handling, and maintenance instructions.
• Key sustainability aspects, such as durability, reparability, or recyclability indicators.

This data must be accurate, clear, and kept up to date.

It enables customers, retailers, and recyclers to understand the product’s characteristics and to manage it responsibly during use and at end of life.

🟡 2. Information Accessible to Persons with Legitimate Interest and the Commission

The second level concerns high‑detail information that could reveal design know‑how if disclosed indiscriminately. Access is therefore limited.

This level may cover:

• Detailed composition information and bill‑of‑materials data.
• Disassembly and dismantling instructions that go beyond user manuals.
• Technical specifications needed for professional repair, refurbishment, or recycling.

Access can be granted to:

• Persons who can demonstrate a legitimate interest, such as professional repairers, independent recyclers, or specific business partners.
• The European Commission, in order to review implementation and policy outcomes.

Economic operators must define processes to:

• Verify the legitimacy of each request.
• Share only the information required for the stated purpose.
• Protect trade secrets while meeting statutory transparency requirements.

🔵 3. Information Accessible Only to Notified Bodies, Market Surveillance Authorities, and the Commission

This access level is reserved exclusively for entities with a regulatory mandate.

The Digital Product Passport should include information on the product model that is accessible only to:

• Notified bodies responsible for conformity assessment tasks.
• Market surveillance authorities in Member States.
• The European Commission.

The focus is on evidence of compliance, such as:

• Test report results demonstrating conformity with applicable EU regulatory requirements.
• Documentation requested under delegated or implementing acts linked to the relevant regulation.

By centralizing this Digital Product Passport information, authorities can:

• Validate that conformity assessment procedures have been completed correctly.
• Detect patterns of non‑compliance across product categories or markets.
• Act rapidly when unsafe or non‑compliant products are identified.

Manufacturers and importers must ensure that test reports and related documentation are digitalized, linked to the correct product model, and retained for the legally required period.

🟣 4. Individual Product Information Accessible to Persons with Legitimate Interest 

The fourth level covers information relating to individual product units rather than the model.

It is treated as classified, and access is limited to identified persons for specific purposes.

Examples of individual‑product data include:

• Serial number and batch‑level traceability records.
• History of significant repairs, refurbishments, or modifications.
• Incident, recall, or warranty data linked to a specific unit.

Access is possible for persons with a documented legitimate interest, such as:

• Authorities investigating a safety event.
• Professional repairers needing complete history for a complex repair.
• Business customers requiring traceability for critical applications.

Economic operators should put in place robust access control, authentication, and logging mechanisms to record who accessed this information, when, and for what reason.

⚙️ Compliance Responsibilities for Economic Operators

Implementing these four access levels of Digital Product Passport information requires coordinated efforts across technical, legal, and IT teams. Key tasks include:

• Data mapping and classification
• Identify all product, safety, and sustainability data.
• Assign each data set to the appropriate access level.

• Governance and procedures
• Define roles and responsibilities for managing passport data.
• Establish workflows for handling legitimate‑interest requests and authority queries.

• System design and security
• Ensure the Digital Product Passport infrastructure can technically restrict access based on user role and legal basis.
• Maintain version control and audit trails for any modifications to passport entries.

• Training and documentation
• Train staff on the distinction between public, restricted, and classified information.
• Keep clear records to demonstrate compliance during inspections and market surveillance actions.

🤝 Preparing Your Organisation for DPP Requirements

Early preparation for Digital Product Passport obligations can reduce future compliance risk and support smoother market access.

ComplyMarket supports manufacturers, importers, and brand owners by:

• Structuring and classifying Digital Product Passport information according to EU access levels.
• Reviewing existing test reports and technical files for integration into passport systems.
• Designing compliant procedures for legitimate‑interest assessments and authority interactions.
• Aligning Digital Product Passport data with broader product safety, sustainability, and market surveillance requirements.

By approaching Digital Product Passport implementation as a structured compliance project, businesses can enhance transparency, protect sensitive information, and ensure long‑term conformity with evolving European regulations.